On April 21, 2022, in Brown v. Davenport, U.S. Supreme Court majority opinion approvingly cited a passage from Rudman Center director John Greabe’s article The Riddle of Harmless Error Revisited, 54 Houston Law Review 59 (2016).
The case addressed how federal judges should conduct harmless-error review in habeas corpus cases where they find a constitutional error to have occurred. The article proposed that the Court undertake a series of reforms to its harmless-error doctrines.
“I was very honored to have the Supreme Court cite my work,” said Professor Greabe. “I hope that, over time, they consider reforming the very complex series of doctrines that regulate whether convicts whose trials were tainted by constitutional error should be provided remedies for those violations.”
Professor Greabe, who teaches constitutional law, has been director of the Warren B. Rudman Center since 2018.
Professor Greabe’s The Riddle of Harmless Error Revisited also was cited in a concurrence by Justice McCullough of the Virginia Supreme Court in Chesapeake Hosp. Auth. V. State Health Commissioner, (May 18, 2022).
About the Warren B. Rudman Center
The Warren B. Rudman Center for Justice, Leadership & Public Service at the UNH Franklin Pierce School of Law serves as a hub for public discourse on the policies and current events that shape our society. It provides programmatic and financial support for students interested in exploring careers in public service while supporting public programming and academic inquiry that align with its mission. The Center honors former U.S. Senator Warren B. Rudman, also the state’s attorney general, who was widely admired for his integrity and willingness to work with politicians across the aisle to advance the public interest.
